Payne v. ACA, No. 11-389, 2014 WL 562986 (D.D.C. Feb. 11, 2014) (Reeves, J.)

Payne v. ACA, No. 11-389, 2014 WL 562986 (D.D.C. Feb. 11, 2014) (Reeves, J.)

Re:  Request for progress report concerning plaintiff

Disposition: 

• Procedural Requirements, Proper FOIA Requests:  The court finds that "[t]hough Plaintiff also referenced the [FOIA], he has not established that he made a proper FOIA request."  The court explains that "[p]laintiff's request for a progress report, a document Defendant [] would presumably have had to create for him, together with a list of representatives or agencies that might assist him, which is readily available public information, is not such a request."